ML19353B200

Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation

ML19353B200
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/04/1989
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 0CAN128903, 54FR33983-00023, 54FR33983-23, CAN128903, NUDOCS 8912130182
Download: ML19353B200 (6)

Text

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December 4, 1989 i

SCAN 128953 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1 137 h3 Washington, D.C. 20555 ATTN: Mr. Samuel J. Chilk 54PO3W3 '

Secretary of the Commission g

Subject:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Draft Regulatory Guide DG-1001, Maintenance Programs for Nuclear Power Plants Gentlemen:

On August 1,1989, the Nuc1 car Regulatory Comission requested csmments on the Draft Regulatory Guide DG-1001, Maintenance Programs for Nuclear Power Plants. This letter transmits Arkansas Power & Light s (AP&L) comments on the proposed regulatory guide. AP&L supports the opinions expressed by the Nuclear Management and Resources Council Inc. (NUMARC) on this proposed regulatory guide.

AP&L supports.the philosophy of proper maintenance as an inportant part of safe and reliable nuclear power plant operation. AP&L has taken steps to upgrade maintenance personnel perfomance by constructing a new, well equipped Maintenanco Facility, expanding and improving mt.intenance training, emphasizing good work 3racticos, rewriting maintenance procedures to a standardized guide wit 1 emphasis on human factors, and upgrading our vendor technical manuals .

To continue the trend of improvements of maintenance activities at ANO, AP&L is partici1ating in consolidated utility activities associated with EPRI, INPO, NUMARC, NSSS Owners Groups, and Codes and Standards Developing Organizations. These groups are addressing improvements in the areas of scif assessment, performance monitoring,1cng-range goals, training, equipment reliability, root cause enelysis, and preventive / predictive maintenance. Having reviewed the draft regulatory guide in detail and considering the industry and NRC activities in the area of maintenance, AP&L believes that the intent of the regulatory guide can be met by other means.

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Page 2 December 4,~1989 .

i, AP&L provides the following responses to the specific questions posed by the l NRC:-

f: Question.I' What' level of detail should be included in the regulatory guide?

Respnnse In general the content of the draft regulatory uide is written at an appropriate level of detail. This allows the f exibility for the utility to have procedures to define its specific maintenance program.

Some improvements, however, are recommended. The addition of examples and/or additional information to describe the intent would ensure consistency of interpretation. In previous regulatory guides the E technique of providing questions with their responses as part of the

-regulatory guide helped to ensure a consistent interpretation.

-Further, the use of vague terms such as " effective" has the potential for subjective interpretation. Defining or eliminating such terms would be appropriate. Another alternative would be qualify terms with "as determined by utility management assessment.,ing This the would indicate that the element is to be interpreted by the individual ,

!- utility. l Question 2 Is the scope of systems, structures, and components covered by the  !

- regulatory guide appropriate? j Resp _o_nse The scope of including all systems, structures, and components, as reflected in the policy statement, is too broad. Use of the '

methodology being developed by the utility industry for the selection of equipment as a result of appropriate technical assessment is more appropriate. This would allow each utility to base its selection of equipment on plant specific experience and revisions to the list would be accomplished in a timely manner. Use of this methodology would '

further minimize interpretational differences between the NRC and the i utility. Currently AP&L maintains equipment appropriate to the >

equipment's importance to safety and the individual components' design.

The intent is to converge both the regulatory and industry emphasis on a specific set of important equipment, i

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U. S. NRC Page 3 December 4, 1989 Question 3 What criteria could be used to determine that a maintenance program is fully effective and additional improvement is not essential from a '

safety standpoint?

Response

Multiple measures are needed to determine the effectiveness of naintenance performance. The regulatory processes and industry programs and controls, in the aggregate, when appropriately implemented, monitored, and adjusted on en on-going basis ensure safety. Long term experience with the NRC and INP0 evaluation processes indicates areas of needed improvenent are identified and rer,olved. Similarly, overall performance indicators presently in use by the NRC and industry facilitate short-term and long-term identification of adverse trends.

Question 4 Is it appropriate to use s,uantitative goals, which are described in Regulatory Position 3 of the draft regulatory guide, directed toward '

achieving a satisfactory level of performance in plant maintenance programs consistent with the level achieved by the top performing U.S. ,

plants of similar design?

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Response

from a regulatory perspective, it is not appropriate to use quantitative goals to achieve a satisfactory level of performanco in plant maintenance. Use of goals and objectives established by the utility to address specific performance problems is appropriste. Use of this management tool would ensure that the plant operates in a safe and reliable manner. Distorting the focus of maintenance activities to meet specific regulatory guides could lead to incorrect decisions resulting in reduced availability and operating less safely than could be otherwise achieved. Striving for safe and reliable plant operation should be the basis for :naintenance activities. Comparison of equipment failures with the plant specific and industry experience would achieve a more realistic approach to maintenance activities. It is also appropriate for the utility to compare its performance with plants of similar design to provide areas for focus of maintenance activities. However, plant specific elements should provide precedence for focus of emphasis.

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U. S. NRC .

Page 5 December 4, 1989 i, i'

cc: V. S, Nuclear Regulatory Comission Document Control Desk .i Mail Station P1-137- ,

L Washington, DC 20555 .

Mr. Robert Martin U. 5. Nuclear Regulatory Commission .

Region IV .:

i 611 Ryan Plaza Drive. Suite 1000  !

, Arlington, TX 76011 .

Mr. C, Craig Harbuck NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Coninission  ;

NRR Mail Stoo 13-D-18 One White Flint North  ;;

11555 Rockville Pike Rockville, Maryland 20852 ,

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Mr. Chester Poslusny NRR Project Manager, Region IV/ANO-2 '-

1 U. S. Nuclear Regulatory Comission NRR Mail Stop 13 D-18 .

One White Flint North J 11555 Rockville Pike Rockville,' Maryland 20852 4

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i U. S. NRC Page 3 I December 4, 1989 Question 3

- What criteria could be used to determine that a maintenance program is fully effective and additional improvement is not essential from a safety standpointi Respons_e 'l Multiple measures are needed to determine the effectiveness of maintenance performance. The regulatory processes and industry  ;

programs and controls, in the aggregate, when appropriately implemented, monitored, and adjusted on an on-going basis ensure safety. Long-term experience with the NRC and INPO evaluation ,

processes indicates areas of needed . improvement are identified and resolved. Similarly, overall performance indicators presently in use by the NRC and industry facilitate short-term and long-term identification of adverse trends.

Question'4 Is it appropriate to uso quantitative goals, which are described in C Regulatory Position 3 of the draft regulatory guide, directed-toward achieving.a satisfactory level of perfontance in plant maintenance programs consistent with the level achieved by the top performing U 3.

plants of similar design? L N

Respons_e From a regulatory perspective, it is not appropriate to use F quantitative goals to achieve a satisfactory level of performance in plant maintenance. Use of goals and objectives established by the utility to address specific performance problems is appropriate. Use of this management tool would ensure that the plant operates in a safe and reliable manner. -Distorting the focus of maintenance activities to meet specific regulatory guides could lead to incorrect decisions resulting in reduced availability and operating less safely than could be otherwise achieved. Striving for safe and reliable plant operation Comparison of should be the basis for maintenance activities.

equipment failures with the plant specific and industry experience would achieve a more realistic approach to maintenance activities. It is also appropriate for the utility to compare its performance with plants of similar design to provide areas for focus of maintenance activities. However, plant specific elements should provide precedence for focus of emphasis.

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L U 5. NRC Page 4 December 4, 1989 Question 5 Wiat quantitative measures would be appropriate for such goals? Should they be at the plant level, system level, component level, or some combination thereof?

Respons_e The INPO performance indicator program t.stablishes overall performance indicators and 'cals. AP&L currently monitors msinyrnsnvr performance at a plant level as part of its goals and objectives program and feels this level of performance monitoring is appropriote. Octermination of ap>ropriate performance monitoring for the achievement of long-term and $1 ort-term objectives, consistent with the individual improvement '

needed, should be plant specific and determined by the utility.

i AP&L-appreciates the opportunity to provide comments on this draft regulatory guide. We consider a well planned maintenance program to be of ,d utmost importance in tL safe and reliable operation of Arkansas Nuclear One and will continue to work with utility groups and the NRC to achieve this goal, o

Very truly yours, r

A/s T. G. Cam- ell ij TGC/lw b

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